Congress, however, did pass a law requiring that every state admitted to the union after 1876 put a provision in its constitution stating that it would maintain a public school system "free from sectarian control.

However, the appellate court found the trial court's decision that Ivy's consent to search was voluntary to be clearly erroneous and suppressed the evidence found during the course of the unlawful search, stating that:

A number of these states, including Iowa and Connecticut, have issued bulletins stating their statutes have been rendered unenforceable as a result of Quill, but they will increase enforcement efforts against the ultimate consumers, both businesses and individuals, for payment of the use tax.

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